Integrate
ETHGAS

$GWEI (GWEI) White paper

In accordance with Title II of Regulation (EU) 2023/1114 (MiCA)

General information about the other token

00 Table of content

Contents

01 Date of notification

2026-02-19

02 Statement in accordance with Article 6(3) of Regulation (EU) 2023/1114

This crypto-asset white paper has not been approved by any competent authority in any Member State of the European Union. The person seeking admission to trading of the crypto-asset is solely responsible for the content of this crypto-asset white paper.

03 Compliance statement in accordance with Article 6(6) of Regulation (EU) 2023/1114

This crypto-asset white paper complies with Title II of Regulation (EU) 2023/1114 of the European Parliament and of the Council and, to the best of the knowledge of the management body, the information presented in the crypto-asset white paper is fair, clear and not misleading and the crypto-asset white paper makes no omission likely to affect its import.

04 Statement in accordance with Article 6(5), points (a), (b), (c), of Regulation (EU) 2023/1114

The crypto-asset referred to in this crypto-asset white paper may lose its value in part or in full, may not always be transferable and may not be liquid.

05 Statement in accordance with Article 6(5), point (d), of Regulation (EU) 2023/1114

N/A

06 Statement in accordance with Article 6(5), points (e) and (f), of Regulation (EU) 2023/1114

The crypto-asset referred to in this white paper is not covered by the investor compensation schemes under Directive 97/9/EC of the European Parliament and of the Council or the deposit guarantee schemes under Directive 2014/49/EU of the European Parliament and of the Council.

SUMMARY

07 Warning in accordance with Article 6(7), second subparagraph, of Regulation (EU) 2023/1114

Warning
This summary should be read as an introduction to the crypto-asset white paper.
The prospective holder should base any decision to purchase this crypto –asset on the content of the crypto-asset white paper as a whole and not on the summary alone.
The offer to the public of this crypto-asset does not constitute an offer or solicitation to purchase financial instruments and any such offer or solicitation can be made only by means of a prospectus or other offer documents pursuant to the applicable national law.
This crypto-asset white paper does not constitute a prospectus as referred to in Regulation (EU) 2017/1129 of the European Parliament and of the Council or any other offer document pursuant to Union or national law.

08 Characteristics of the crypto-asset

The ETHGas project, represented by the GWEI token, is designed primarily as a governance mechanism within the Ethereum ecosystem. It allows stakeholders to participate in the decision-making processes regarding protocol upgrades, resource allocation, and governance mechanics through proposal creation, voting, and delegation. As such, the token does not confer specific ownership rights, entitle holders to dividends, or grant voting rights in the traditional sense of corporate governance. All rights associated with GWEI are governed by the protocol rules, which may evolve through community consensus and upgrades. Importantly, rights and obligations attached to the GWEI token are bound by the protocol’s smart contracts and community governance decisions.

GWEI token holders are not automatically entitled to participate in or vote on changes unless they qualify as stakeholders within the ETHGas protocol ecosystem, primarily through staking mechanisms. Furthermore, to participate effectively, holders must comply with technical requirements, such as participating in the network's staking protocol.

09 Further information about utility tokens

N/A

10 Key information about the offer to the public or admission to trading

No offer of Ethgas (GWEI) tokens is made to the public in connection with this disclosure. There is no new issuance, subscription period, fundraising, target subscription goal, issue price, or subscription fee.

The admission to trading of Ethgas (GWEI) on Bitvavo B.V. is not linked to any new or ongoing discounted purchase arrangements, pre-sales, or staged offerings. Admission is sought solely to provide market access, liquidity, and regulated availability for eligible users in the European Economic Area.

No crypto-asset service provider has been appointed to place the token on a firm commitment or best effort basis. Use of the trading platform is subject to the terms and conditions of Bitvavo B.V., with fees set independently by the platform.

Part A - Information about the offeror or the person seeking admission to trading

A.1 Name

ETHGas Ltd.

A.2 Legal form

GQ8F

A.3 Registered address

Registered address

Trinity Chambers, PO BOX 4301, Road Town, Tortola, British Virgin Islands

Country

Sub-division

Tortola

A.4 Head office

Head office

Trinity Chambers, PO BOX 4301, Road Town, Tortola, British Virgin Islands

Country

Sub-division

Tortola

A.5 Registration date

2025-10-21

A.6 Legal entity identifier

N/A

A.7 Another identifier required pursuant to applicable national law

2190570

A.8 Contact telephone number

12844948445

A.9 E-mail address

Kevin@ethgas.com
Rob@ethgas.com

A.10 Response time (days)

014

A.11 Parent company

N/A

A.12 Members of management body

IdentityBusiness addressFunction
K Lepsoe
Trinity Chambers, PO BOX 4301
Road Town
Tortola
British Virgin Islands
Director
R Lepsoe
Trinity Chambers, PO BOX 4301
Road Town
Tortola
British Virgin Islands
Director

A.13 Business activity

Blockchain software development

A.14 Parent company business activity

N/A

A.15 Newly established

true

A.16 Financial condition for the past three years

Not applicable

A.17 Financial condition since registration

Not applicable

Part B - Information about the issuer, if different from the offeror or person seeking admission to trading

B.1 Issuer different from offeror or person seeking admission to trading

false

B.2 Name

N/A

B.3 Legal form

N/A

B.4 Registered address

Country

N/A

Sub-division

N/A

B.5 Head office

Country

N/A

Sub-division

N/A

B.6 Registration date

N/A

B.7 Legal entity identifier

N/A

B.8 Another identifier required pursuant to applicable national law

N/A

B.9 Parent company

N/A

B.10 Members of management body

Line identifier

N/A

Identity

N/A

Business address

N/A

Function

N/A

B.11 Business activity

N/A

B.12 Parent company business activity

N/A

Part C - Information about the operator of the trading platform in cases where it draws up the crypto-asset white paper and information about other persons drawing the crypto-asset white paper pursuant to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

C.1 Name

N/A

C.2 Legal form

N/A

C.3 Registered address

Country

N/A

Sub-division

N/A

C.4 Head office

Country

N/A

Sub-division

N/A

C.5 Registration date

N/A

C.6 Legal entity identifier

N/A

C.7 Another identifier required pursuant to applicable national law

N/A

C.8 Parent company

N/A

C.9 Reason for crypto-asset white paper preparation

N/A

C.10 Members of management body

Line identifier

N/A

Identity

N/A

Business address

N/A

Function

N/A

C.11 Operator business activity

N/A

C.12 Parent company business activity

N/A

C.13 Other persons drawing up the crypto-asset white paper according to Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

N/A

C.14 Reason for drawing the white paper by persons referred to in Article 6(1), second subparagraph, of Regulation (EU) 2023/1114

N/A

Part D - Information about the crypto-asset project

D.1 Crypto-asset project name

ETHGas Ltd.

D.2 Crypto-asset name

$GWEI

D.3 Abbreviation

GWEI

D.4 Crypto-asset project description

ETHGas is a pioneering project designed to revolutionise Ethereum blockspace by transforming it into a tradable commodity. The project aims to propel Ethereum into a real-time network, enhancing efficiency and eliminating gas fees to unlock wider institutional adoption and onboard a billion new onchain users. By allowing participants to purchase blockspace directly from validators, ETHGas creates opportunities for instant, gasless transactions. Moreover, the project endeavours to create a robust market for Ethereum blockspace that maximises execution predictability while minimising transaction anxiety.

D.5 Details of all natural or legal persons involved in implementation of crypto-asset project

Type of personName of personBusiness addressDomicile of company
DevelopmentTeamK LepsoeTrinity Chambers, PO BOX 4301, Road Town, Tortola, British Virgin IslandsVI
DevelopmentTeamR LepsoeTrinity Chambers, PO BOX 4301, Road Town, Tortola, British Virgin IslandsVI

D.6 Utility token classification

false

D.7 Key features of goods or services for utility token projects

N/A

D.8 Plans for the token

Description of past milestones

  • December 2025: Completion of a USD 12 million fundraising round to support the development and scaling of the ETHGas protocol and related infrastructure.
  • 13 January 2026: Public announcement of the ETHGas tokenomics framework, outlining supply, and allocation principles.
  • 19 January 2026: Execution of an airdrop snapshot to determine eligible participants based on predefined criteria.
  • 21 January 2026: Token Generation Event (TGE) and commencement of trading through initial exchange listings.
  • Ongoing: Introduction of community engagement initiatives, including "Beans" quest programs designed to incentivise gas users and early protocol interaction.

Description of future milestones

ETHGas is planned to implement a long-term token emission and vesting schedule spanning approximately ten years, as defined in the tokenomics framework. Future milestones are expected to include the activation of staking mechanisms providing protocol-defined rewards distributed from periodic reward pools, the continuation of multi-season community incentive programs, and the progressive activation of governance functionality enabling token holders to submit proposals and participate in voting processes. The project also plans to allocate treasury resources toward ecosystem development, including grants, liquidity support, and strategic partnerships. The timing and specific parameters of these initiatives may be subject to change.

D.9 Resource allocation

In terms of financial backing, ETHGas has secured a $12 million fundraise, notably led by Polychain Capital. This robust funding supports the project's ongoing development and future growth opportunities. Additionally, participation by key investors including Stake Capital, BlueYard Capital, and Amber Group highlights strong ecosystem support and confidence in ETHGas' strategic vision.

D.10 Planned use of collected funds or other tokens

The token is already in circulation; hence no immediate plans for the use of collected funds were detailed. Future funds might primarily support incentivizing protocol participation, ongoing ecosystem development, liquidity provisions, and covering operational expenses.

Part E - Information about the offer to the public of crypto-assets or their admission to trading

E.1 Public offering or admission to trading

E.2 Reasons for public offer or admission to trading

The admission to trading of $GWEI (GWEI) on Payward Europe Solutions Limited (Kraken) is intended to improve accessibility, liquidity, and application of the token across digital asset markets. There is no associated fundraising or primary issuance of tokens in connection with this listing. This disclosure is filed to enhance transparency, foster regulatory clarity, and support institutional confidence.

By aligning with the high disclosure standards of Regulation (EU) 2023/1114, Payward Europe Solutions Limited (Kraken) reinforces its commitment to operating a secure, compliant, and transparent trading environment. This initiative facilitates broader market access, supports responsible token adoption, and strengthens integration of $GWEI (GWEI) within the regulated financial ecosystem.

E.3 Fundraising target

Target expressed in currency

N/A

Target expressed in units

N/A

Target expressed in digital token identifier

N/A

E.4 Minimum subscription goals

N/A

Goals expressed in currency

N/A

Goals expressed in units

N/A

Goals expressed in digital token identifier

N/A

E.5 Maximum subscription goals

N/A

Goals expressed in currency

N/A

Goals expressed in units

N/A

Goals expressed in digital token identifier

N/A

E.6 Oversubscription acceptance

N/A

E.7 Oversubscription allocation

N/A

Issue price details

N/A

E.8 Issue price

N/A

E.9 Official currency determining issue price or any other tokens determining issue price

N/A

E.10 Subscription fee

N/A

Fee expressed in currency

N/A

Fee expressed in units

N/A

Fee expressed in digital token identifier

N/A

E.11 Offer price determination method

N/A

E.12 Total number of offered or traded other tokens

10000000000

E.13 Targeted holders

E.14 Holder restrictions

Access to the token may be restricted in accordance with the terms and conditions of Payward Europe Solutions Limited (Kraken), including, but not limited to, individuals or entities located in OFAC-sanctioned jurisdictions or users prohibited under the eligibility requirements of third-party platforms where the token is made available.

E.15 Reimbursement notice

N/A

E.16 Refund mechanism

N/A

E.17 Refund timeline

N/A

E.18 Offer phases

N/A

E.19 Early purchase discount

N/A

E.20 Time-limited offer

N/A

E.21 Subscription period beginning

N/A

E.22 Subscription period end

N/A

E.23 Safeguarding arrangements for offered funds or other tokens

N/A

E.24 Payment methods for other token purchase

Purchases of $GWEI (GWEI) on Payward Europe Solutions Limited (Kraken) may be made using supported crypto-assets or other fiat-currencies, as per the available trading pairs on the platform.

E.25 Value transfer methods for reimbursement

N/A

E.26 Right of withdrawal

N/A

E.27 Transfer of purchased other tokens

Purchased $GWEI (GWEI) on Payward Europe Solutions Limited (Kraken) may be withdrawn by the user to a compatible external wallet address, subject to standard withdrawal procedures, network availability, and platform-specific compliance checks.

E.28 Transfer time schedule

N/A

E.29 Purchaser's technical requirements

Purchasers may choose to hold $GWEI (GWEI) within their trading account on Payward Europe Solutions Limited (Kraken). Alternatively, holders can withdraw the asset to a compatible external wallet that supports the $GWEI (GWEI).

Users are responsible for ensuring their chosen wallet supports the withdrawal network used by Payward Europe Solutions Limited (Kraken), and for securely managing their private keys. Incompatible withdrawals may result in permanent loss of crypto-assets.

Other token services provider characteristics

E.30 Other token service provider (CASP) name

N/A

E.31 CASP identifier

N/A

E.32 Placement form

Trading platforms characteristics

N/A

E.33 Trading platforms name

Payward Europe Solutions Limited (Kraken)

E.34 Trading platforms market identifier code (MIC)

PGSL

E.35 Trading platforms access

Investors can access the trading platform operated by Payward Europe Solutions Limited (Kraken) via its official website and user interface, subject to registration and compliance with applicable onboarding and verification procedures.

E.36 Involved costs

There is no cost to access the trading platform operated by Payward Europe Solutions Limited (Kraken). However, investors intending to trade may incur transaction-related fees. A detailed and up-to-date fee schedule is available on the official website of Payward Europe Solutions Limited (Kraken).

E.37 Offer expenses

N/A

E.38 Conflicts of interest

Persons involved in the admission of the crypto-asset to trading may have commercial or contractual arrangements connected to the admission process, including the provision of services for remuneration. These arrangements can give rise to potential conflicts of interest. Admission-related decisions are taken in accordance with established governance, control and conflict-management procedures.

E.39 Applicable law

Irish Law

E.40 Competent court

Courts of Ireland

Part F - Information about the crypto-assets

F.1 Other token type

$GWEI (GWEI) is classified as a crypto-asset other than an asset referenced token or
e-money token under MiCA, (EU) 2023/1114.

F.2 Other token functionality

ETHGas transforms Ethereum blockspace into a tradable and structured asset, providing real-time execution and gasless transactions. It enables participants to purchase blockspace directly from validators, granting them sequencing rights that promote predictability and cost-efficiency. The core objective is to eliminate gas fees, thus reducing barriers for onchain users and fostering higher adoption rates across Ethereum. Each transaction in the ETHGas system contributes towards a gasless future, while different participation mechanics allow users to engage in proposals, voting, and governance processes.

F.3 Planned application of functionalities

The GWEI token, integral to the ETHGas ecosystem, is already deployed and available for use on the Ethereum Mainnet. Current functionalities enable token holders to participate actively in governance through staking, voting, and proposal initiatives. The ETHGas marketplace is operational, allowing for real-time and gasless transaction experiences across the ecosystem.

A description of the characteristics of the other token, including the data necessary for classification of the crypto-asset white paper in the register referred to in Article 109 of Regulation (EU) 2023/1114, as specified in accordance with paragraph 8 of that Article

F.4 Type of crypto-asset white paper

F.5 Type of submission

F.6 Other token characteristics

ETHGas provides a fungible, governance-focused cryptoasset, enabling decentralised stewardship through on-chain decision-making processes. The GWEI token serves as a governance tool within the Ethereum ecosystem, allowing participants to influence various protocol parameters and decisions. The asset does not qualify as an e-money token or an asset-referenced token under Regulation (EU) 2023/1114 and is therefore classified as an 'other crypto-asset' for MiCA purposes.

F.7 Commercial name or trading name

N/A

F.8 Website of the issuer

ETHGas.com

F.9 Starting date of offer to the public or admission to trading

2026-03-19

F.10 Publication date

2026-03-19

F.11 Any other services provided by the issuer

N/A

F.12 Language or languages of white paper

English

F.13 Digital token identifier code used to uniquely identify the crypto-asset or each of the several crypto assets to which the white paper relates, where available

XDG7XHTR8

F.14 Functionally fungible group digital token identifier, where available

ZZGXDPXH7

F.15 Voluntary data flag

false

F.16 Personal data flag

true

F.17 LEI eligibility

true

F.18 Home member state

Part G - Information on the rights and obligations attached to the crypto-assets

G.1 Purchaser rights and obligations

Purchasers of GWEI tokens do not obtain contractual rights, claims against any legal entity, or equity interests in the project. Instead, they participate in the GWEI community ecosystem as a holder of the GWEI token, and can use GWEI as a form of payment for some businesses and partners.

G.2 Exercise of rights and obligations

There are no specific rights or obligations attached to the holding of GWEI that require formal exercise. Any limited functionality or utility associated with GWEI, such as the ability to use GWEI as a form of payment for some businesses and partners, arises solely from the holder’s participation in GWEI’s community ecosystem as a holder of the GWEI token.

G.3 Conditions for modifications of rights and obligations

Any limited functionality or utility associated with GWEI, such as the ability to use GWEI as a form of payment for some businesses and partners, arises solely from the holder’s participation in GWEI’s community ecosystem as a holder of the GWEI token, and can change over time.

G.4 Future public offers

There are no planned future public offerings of GWEI by the issuer. GWEI is already in circulation and is freely transferable on a variety of decentralised and centralised trading venues. Any future increase in the circulating supply, if applicable, will occur in accordance with the protocol’s predefined issuance and unlock schedule. The issuer does not commit to or guarantee any future offering, distribution, or sale of GWEI.

G.5 Issuer retained other token

800000000

G.6 Utility token classification

false

G.7 Key features of goods or services utility tokens

N/A

G.8 Utility tokens redemption

N/A

G.9 Non-trading request

true

G.10 Other tokens purchase or sale modalities

N/A

G.11 Other tokens transfer restrictions

There are no restrictions imposed on the transferability of the GWEI token at the protocol level. The token is already in public circulation and may be freely transferred between users in accordance with the consensus rules of the decentralised network. Transfer functionality is determined by the underlying protocol and may be subject to standard technical conditions such as wallet compatibility, network fees, and block confirmation times. Any limitations that arise are typically due to external factors such as third-party exchange policies, jurisdictional regulatory requirements, or user-specific constraints.

The use of services provided by Payward Europe Solutions Limited (Kraken) may be governed by separate terms and conditions. These may include restrictions or obligations applicable to specific features, interfaces, or access points operated by Payward Europe Solutions Limited (Kraken) in connection with GWEI. Such terms do not alter the native transferability of the token on the decentralised network but may affect how users interact with services linked to it. Users should consult and accept the applicable terms of service before engaging with these services.

This disclosure pertains solely to the transferability of the GWEI token as admitted to trading on Payward Europe Solutions Limited (Kraken). Vesting schedules, lock-up arrangements, or other contractual restrictions related to private sales or early-stage allocations are considered out of scope for this section, as they apply only to specific counterparties and do not affect the native transferability of the token at the network level.

G.12 Supply adjustment protocols

false

G.13 Supply adjustment mechanisms

Ethgas (GWEI) does not implement any supply adjustment mechanisms that respond automatically to changes in market demand. The protocol does not feature dynamic monetary policies such as algorithmic rebasing, elastic supply adjustments, or demand-linked token issuance or burning. Any changes to the total or circulating supply, if applicable, occur according to fixed issuance schedules or protocol rules that are independent of short-term demand fluctuations. Supply remains determined by predefined parameters or community governance, not by automated responses to market conditions.

Other token schemes details

N/A

G.14 Token value protection schemes

false

G.15 Token value protection schemes description

N/A

G.16 Compensation schemes

false

G.17 Compensation schemes description

N/A

G.18 Applicable law

BVI

G.19 Competent court

BVI

Part H - Information on the underlying technology

H.1 Distributed ledger technology (DTL)

ETHGas utilises Ethereum's well-established blockchain, transforming its blockspace into a tradable commodity. As part of its strategy, ETHGas introduces predictability and high-performance execution into transactions, supporting better staking yields and minimising gas price volatility for end-users.

H.2 Protocols and technical standards

In alignment with Ethereum network standards, ETHGas functions as both a hybrid exchange and standardisation engine optimising Ethereum blockspace into structured, tradable financial instruments. This allows for composability and interoperability within Ethereum’s existing infrastructure.

H.3 Technology used

EthGas provides instant settlement functionality supported by protocol infrastructure that secures blockspace commitments. The technology enables transactions to be executed at predefined times and is designed to support high-throughput use cases. The protocol’s smart contract components have undergone an external security audit conducted by Sigma Prime, with a focus on security and operational integrity.

H.4 Consensus mechanism

ETHGas itself does not operate a native consensus mechanism but rather relies on Ethereum's existing Proof of Stake consensus, utilising Ethereum's network infrastructure to deliver its services.

H.5 Incentive mechanisms and applicable fees

To incentivize transactions, ETHGas rebates gas fees via partnerships with protocols keen to promote specific transaction types, effectively lowering costs and promoting activity within the Ethereum ecosystem.

H.6 Use of distributed ledger technology

false

H.7 DLT functionality description

N/A

Other token audit details

H.8 Audit

true

H.9 Audit outcome

A comprehensive technology audit was conducted by Sigma Prime, which underscored the protocol's commitment to robust security standards and confirmed the operational reliability of ETHGas’ infrastructure and mechanisms.

Part I - Information on risks

I.1 Offer-related risks

$GWEI (GWEI) is already in public circulation and the current action relates to its admission to trading, rather than a new offer to the public. Nevertheless, risks associated with the admission process include:

Market Volatility: Crypto-assets, including $GWEI (GWEI), are subject to significant price fluctuations due to market speculation, regulatory developments, liquidity shifts, and macroeconomic factors.

Information Asymmetry: Due to the decentralised and open-source nature of $GWEI (GWEI), not all market participants may have access to the same level of technical understanding or information, potentially leading to imbalanced decision-making.

Listing Risk: Admission to trading on specific platforms does not guarantee long-term availability, and trading venues may delist the asset due to internal policy, regulatory enforcement, or liquidity thresholds.

Jurisdictional Restrictions: The regulatory treatment of crypto-assets varies between jurisdictions. Traders or investors in certain regions may face legal limitations on holding or transacting $GWEI (GWEI).

Exchange Risk: While exchanges may implement robust operational, cybersecurity, and compliance controls, no exchange is immune to operational disruptions, cyber threats, or evolving regulatory constraints. Users should be aware that exchange-level risks - such as service outages, wallet access delays, or changes in platform policy - may impact the ability to trade or withdraw $GWEI (GWEI). Legal and technical developments may affect the platform’s capacity to continue offering certain assets, including $GWEI (GWEI). Users should ensure they have read the terms of service before engaging with any service.

Market participants should conduct their own due diligence and consider their risk tolerance prior to engaging in the trading of $GWEI (GWEI).

I.2 Issuer-related risks

Information accuracy: Information published by the issuer, including on websites or technical materials, may be incomplete, inaccurate, or out of date. Misstatements or omissions can lead to incorrect assumptions about $GWEI (GWEI) and may expose holders to unexpected losses.

Governance and oversight: The issuer’s governance arrangements may be limited or highly centralised. Weak oversight or concentrated decision-making can lead to poor strategic choices or inconsistent project direction, and conflicts of interest may arise where insiders hold significant positions or influence outcomes.

Conduct and integrity: Individuals involved with the issuer may engage in misconduct, including mismanagement, diversion of funds, or false representations. Such behaviour may negatively affect the development, viability, or perception of $GWEI (GWEI) and may leave holders with limited recourse.

Technical and implementation risk: The issuer may be responsible for development, deployment, or maintenance of technology supporting $GWEI. Errors in design, implementation, upgrades, or security practices may affect functionality or lead to loss of assets, and new or untested technology may not perform as intended under all conditions.

Operational resilience: The issuer may rely on internal systems and external providers for essential functions. Service disruptions, security incidents, or failures of operational processes may impair access to information or supporting services relevant to $GWEI (GWEI).

Regulatory exposure: The issuer is subject to changing legal and regulatory requirements across jurisdictions. Compliance failures or regulatory action may restrict the issuer’s activities or the availability of GWEI, and divergent regulatory interpretations may create uncertainty for users and market participants.

Financial viability: The issuer may experience financial difficulties, including reduced funding, liquidity constraints, or insolvency. Limited financial resources may affect the issuer’s capacity to support ongoing work or maintain operations relating to $GWEI.

Dependence on individuals and third parties: The issuer may rely on a small number of key people or specialised service providers. Loss, withdrawal, or underperformance of such individuals or providers may disrupt project continuity and affect the development or maintenance of $GWEI (GWEI).

Investor protection limitations: Holding GWEI generally does not grant rights or protections associated with traditional financial instruments. Holders may have no claim over issuer assets and no access to compensation schemes in the event of losses or issuer failure.

Unforeseen risks: Additional risks may arise that cannot be identified in advance, including those stemming from technological developments, market conditions, regulatory changes, or internal circumstances. Such risks may affect the issuer’s operations or the use and perception of $GWEI.

I.3 Other tokens-related risks

Volatility risk: Crypto-assets are subject to significant price volatility, which may result from market speculation, shifts in supply and demand, regulatory developments, or macroeconomic trends. This volatility can affect the asset’s value independently of the project’s fundamentals.

Liquidity risk: The ability to buy or sell the crypto-asset on trading platforms may be limited by market depth, exchange availability, or withdrawal restrictions, potentially impairing the ability of holders to exit positions efficiently or at desired prices.

Regulatory risk: The evolving global regulatory landscape may impose new restrictions, classifications, or disclosure requirements that could impact the legal treatment, availability, or use of the crypto-asset. Changes in regulation may also affect the token’s classification or trigger enforcement actions.

Exchange-related risk: The crypto-asset may rely on third-party trading platforms for liquidity and price discovery. These platforms are subject to operational, custodial, or legal risks, including suspension of trading, delistings, or platform failure, which may adversely affect access to the asset.

Custody and private key risk: Holders of crypto-assets are typically responsible for managing private keys or access credentials. Loss, theft, or compromise of these keys may result in irreversible loss of the associated assets without recourse or recovery.

Market manipulation risk: The crypto-asset may be susceptible to pump-and-dump schemes, wash trading, or other forms of market manipulation due to limited oversight or fragmented market infrastructure, which can distort price signals and mislead participants.

Perception and reputational risk: Public sentiment, media narratives, or association with controversial projects or exchanges may influence the perception of the crypto-asset, affecting its adoption, market value, and long-term viability.

Forking risk: Blockchain networks may undergo contentious upgrades or forks, potentially resulting in duplicate tokens, split communities, or compatibility challenges that affect the asset’s continuity or utility.

Legal ownership risk: Depending on jurisdiction and platform terms, holders may not acquire legal ownership or enforceable rights with respect to the crypto-asset, which could affect recourse options in the event of fraud, misrepresentation, or loss.

Network usage risk: A decline in activity or utility on the associated network may reduce the economic relevance of the crypto-asset, diminishing its value and undermining its role as a medium of exchange or utility token.

Compliance risk: Holders may be subject to local obligations related to tax reporting, anti-money laundering (AML), or sanctions compliance. Failure to meet these obligations could result in penalties or legal consequences.

Cross-border risk: Transactions involving the crypto-asset may span multiple jurisdictions, creating uncertainty around applicable laws, conflict-of-law issues, or barriers to enforcement and regulatory clarity.

Incentive misalignment risk: The crypto-asset’s economic model may depend on incentives for participants such as validators, developers, or users. If these incentives become insufficient or distorted, network participation and security may decline.

Token distribution concentration risk: A disproportionate concentration of token supply in the hands of a small number of holders may enable price manipulation, governance capture, or coordinated sell-offs that impact market stability and community trust.

Misuse risk: The crypto-asset may be used for illicit purposes (e.g., money laundering, ransomware payments), exposing the project to reputational harm or regulatory scrutiny, even if such activity is beyond the issuer’s control.

Utility risk: The expected utility of the token within its ecosystem may fail to materialize due to low adoption, under-delivery of promised features, or technical incompatibility, undermining its value proposition.

Inflation or deflation risk: The token’s supply mechanics (minting, burning, vesting, etc.) may introduce inflationary or deflationary dynamics that affect long-term holder value and purchasing power within the network.

Secondary market dependence risk: The ability of users to access, trade, or price the token may depend entirely on secondary markets. If such platforms restrict or delist the asset, liquidity and discoverability may be severely impacted.

Taxation risk: The treatment of crypto-assets for tax purposes may vary by jurisdiction and change over time. Holders may face unanticipated tax liabilities related to capital gains, income, or transaction activity.

Bridging risk: If the crypto-asset exists on multiple blockchains via bridging protocols, vulnerabilities in those bridges may lead to de-pegging, duplication, or irrecoverable losses affecting token integrity and user balances.

Incompatibility risk: The crypto-asset may become technically incompatible with evolving wallets, smart contracts, or infrastructure components, limiting its usability and support within the broader crypto ecosystem.

Network governance risk: If governance decisions (e.g., protocol upgrades, treasury usage) are controlled by a limited set of actors or are poorly defined, outcomes may not align with broader user interests, leading to fragmentation or disputes.

Economic abstraction risk: Users may be able to interact with the network or ecosystem without using the crypto-asset itself (e.g., via gas relayers, fee subsidies, or wrapped tokens), reducing demand for the token and weakening its economic role.

Dust and spam risk: The crypto-asset may be vulnerable to dust attacks or spam transactions, creating bloated ledgers, user confusion, or inadvertent privacy exposure through traceability.

Jurisdictional blocking risk: Exchanges, wallets, or interfaces may restrict access to the crypto-asset based on IP geolocation or jurisdictional policies, limiting user access even if the asset itself remains transferable on-chain.

Environmental or ESG risk: The association of the crypto-asset with energy-intensive consensus mechanisms or unsustainable tokenomics may conflict with emerging environmental, social, and governance (ESG) standards, affecting institutional adoption.

I.4 Project implementation-related risks

Development risk: The project may experience delays, underdelivery, or changes in scope due to unforeseen technical complexity, resource constraints, or coordination issues, impacting timelines and stakeholder expectations.

Funding risk: The continued implementation of the project may depend on future funding rounds, revenue generation, or grants. A shortfall in available capital may impair the project’s ability to execute its roadmap or retain key personnel.

Roadmap deviation risk: Strategic shifts, pivots, or reprioritization may result in deviations from the originally published roadmap, potentially leading to dissatisfaction among community members or early supporters.

Team dependency risk: The project’s success may be heavily dependent on a small number of core contributors or founders. The departure, unavailability, or misconduct of these individuals could significantly impair execution capacity.

Third-party dependency risk: Certain components of the project (e.g., infrastructure providers, integration partners, oracles) may rely on external entities whose performance or continuity cannot be guaranteed, introducing operational fragility.

Talent acquisition risk: The project may face challenges recruiting and retaining qualified professionals in highly competitive areas such as blockchain development, AI engineering, security, or compliance, slowing implementation or reducing quality.

Coordination risk: As decentralized or cross-functional teams grow, internal coordination and alignment across engineering, product, legal, and marketing domains may become difficult, leading to delays, errors, or strategic drift.

Security implementation risk: Insufficient diligence in implementing security protocols (e.g., audits, access controls, testing pipelines) during development may introduce critical vulnerabilities into the deployed system.

Scalability bottleneck risk: Architectural decisions made early in the project may limit performance or scalability as usage grows, requiring resource-intensive refactoring or redesign to support broader adoption.

Vendor lock-in risk: Reliance on specific middleware, cloud infrastructure, or proprietary tools may constrain the project’s flexibility and increase exposure to price shifts, service outages, or licensing changes.

Compliance misalignment risk: Product features or delivery mechanisms may inadvertently breach evolving regulatory requirements, particularly around consumer protection, token functionality, or data privacy, necessitating rework or geographic limitations.

Community support risk: The project’s success may rely on active developer or user participation. If the community fails to engage or contribute as anticipated, ecosystem momentum and resource leverage may decline.

Governance deadlock risk: If project governance (e.g., DAO structures or steering committees) lacks clear decision-making processes or becomes fragmented, the project may face delays or paralysis in critical strategic decisions.

Incentive misalignment risk: Implementation plans may fail to maintain consistent alignment between stakeholders such as developers, token holders, investors, and users, undermining cooperation or long-term sustainability.

Marketing and adoption risk: Even with timely technical delivery, the project may fail to gain market traction, user onboarding, or brand recognition, reducing the effectiveness of its deployment.

Testing and QA risk: Inadequate testing coverage, staging environments, or quality assurance processes may allow critical bugs or regressions to reach production, causing service degradation or user loss.

Scope creep risk: Expanding project objectives without adequate resource reallocation or stakeholder alignment may dilute focus and overextend the development team, compromising quality or deadlines.

Interoperability risk: Implementation plans involving cross-chain or cross-platform integration may encounter compatibility issues, protocol mismatches, or delays in third-party upgrades.

Legal execution risk: If foundational legal structures (e.g., entities, IP assignments, licensing) are not finalized or enforceable across key jurisdictions, the project may face friction during scaling, partnerships, or fundraising.

I.5 Technology-related risks

Smart contract risk: The crypto-asset may rely on smart contracts that, if improperly coded or inadequately audited, can contain vulnerabilities exploitable by malicious actors, potentially resulting in asset loss, unauthorized behavior, or permanent lock-up of funds.

Protocol risk: The underlying blockchain protocol may contain unknown bugs, suffer from unanticipated behavior, or experience edge-case failures in consensus, finality, or synchronization, leading to disruptions in network operation.

Bridge risk: If the crypto-asset is deployed across multiple chains via bridging infrastructure, the underlying bridge may be vulnerable to exploit, misconfiguration, or oracle manipulation, threatening asset integrity across networks.

Finality risk: Some blockchains may exhibit probabilistic or delayed finality, making transactions theoretically reversible within short windows. This can lead to issues in cross-chain settlements or operational reliability.

Node centralization risk: If the network depends on a small number of validators or infrastructure providers to maintain consensus or data availability, it may be susceptible to downtime, censorship, or coordinated manipulation.

Data integrity risk: In decentralized environments, reliance on off-chain data (e.g., oracles or external feeds) introduces the possibility of incorrect or manipulated information entering the system and triggering undesired outcomes.

Versioning and upgrade risk: Protocol upgrades, forks, or version mismatches between nodes and clients can introduce compatibility issues or destabilize service availability, particularly if coordination or governance processes are insufficient.

Storage and archival risk: The technical infrastructure supporting the crypto-asset may be vulnerable to data loss or corruption, particularly in cases involving third-party storage solutions, partial nodes, or decentralized file systems.

Interoperability risk: Integration with third-party tools, blockchains, or application layers may rely on APIs, SDKs, or interfaces that change without notice or suffer from inconsistencies, potentially breaking user functionality or asset movement.

Scalability risk: The underlying technology may not scale effectively under high usage conditions, leading to network congestion, transaction delays, fee spikes, or degraded user experience.

Cryptographic risk: The system relies on current cryptographic standards for key generation, digital signatures, and hashing. Advances in computing (e.g., quantum computing) or undiscovered flaws may undermine these protections in the future.

Permissioning or access control risk: If token behavior or network features are governed by privileged roles (e.g., admin keys, multisigs), improper key management, role abuse, or governance capture could impact fairness or security.

Decentralization illusion risk: Despite being labeled “decentralized,” critical components (e.g., governance, token distribution, node operation) may be technically or operationally centralized, concentrating risk and reducing resilience.

Latency and synchronization risk: Distributed networks may experience propagation delays, inconsistent state views, or latency in consensus confirmation, introducing unpredictability in transaction ordering and agent coordination.

Frontend dependency risk: End users may rely on centralized interfaces (e.g., websites, wallets, APIs) to interact with the asset, which if compromised or taken offline, can block access despite the network itself being operational.

Misconfiguration risk: Errors in smart contract deployment, token configuration, permission settings, or network parameters can result in unintended behavior, including frozen assets, incorrect balances, or bypassed restrictions.

Monitoring and observability risk: Insufficient logging, alerting, or metrics may prevent the timely detection of technical issues, exploits, or usage anomalies, limiting the project's ability to respond to emergent threats.

Software dependency risk: Core components may depend on open-source libraries or packages that are unmaintained, vulnerable, or deprecated, exposing the asset to cascading failures or inherited security flaws.

Time drift and clock sync risk: Distributed ledgers that rely on timestamping may face issues if nodes do not maintain consistent system time, impacting consensus, block ordering, or event sequencing.

Blockchain immutability risk: Once deployed, certain design flaws or oversights may be difficult or impossible to correct due to the immutable nature of smart contracts or protocol rules, necessitating workarounds or forks.

I.6 Mitigation measures

The ETHGas protocol emphasises risk mitigation by involving Sigma Prime in auditing its technology, fostering open-source development practises, and forming a participatory governance structure. Users also benefit from ETHGas’ incorporation of widely adopted Ethereum standards, which ensures protocol compatibility and community engagement. Ongoing community input and governance assure proactive adaptation to emerging needs, while validator involvement solidifies resistance to unilateral signalling.

Part J - Information on the sustainability indicators in relation to adverse impact on the climate and other environment-related adverse impacts

J.1 Adverse impacts on climate and other environment-related adverse impacts

The environmental impacts associated with this crypto-asset arise from the operation of the blockchain network on which it exists. These impacts depend on the network’s consensus mechanism, infrastructure, and transaction-processing activity. Where the crypto-asset is a native token of its own network, impacts relate to the network’s overall operation. Where it is a token issued on another network, impacts arise from the energy usage and processes of that underlying network. No additional computational requirements specific to this token have been identified beyond normal use of the network.

Mandatory information on principal adverse impacts on the climate and other environment-related adverse impacts of the consensus mechanism

General information about adverse impacts

S.1 Name

ETHGas Ltd.

S.2 Relevant legal entity identifier

GQ8F

S.3 Name of the crypto-asset

$GWEI

S.4 Consensus mechanism

See H.4

S.5 Incentive mechanisms and applicable fees

See H.5

S.6 Beginning of period to which disclosed information relates

2026-02-19

S.7 End of period to which disclosed information relates

2027-02-19

Mandatory key indicator

S.8 Energy consumption

91.0354

Sources and methodologies

S.9 Energy consumption sources and methodologies

www.archax.com/dlt-sustainability-assessment

Supplementary information on principal adverse impacts on climate and other environment-related adverse impacts of the consensus mechanism

Supplementary key indicators

S.10 Renewable energy consumption

N/A

S.11 Energy intensity

N/A

S.12 Scope 1 DLT GHG emissions - controlled

N/A

S.13 Scope 2 DLT GHG emissions - purchased

N/A

S.14 GHG intensity

N/A

Sources and methodologies

S.15 Key energy sources and methodologies

N/A

S.16 Key GHG sources and methodologies

N/A

Optional information on principal adverse impacts on the climate and on other environment-related adverse impacts of the consensus mechanism

Optional indicators

S.17 Energy mix

N/A

S.18 Energy use reduction

N/A

Energy use reduction target (absolute value)

N/A

Energy use reduction target (percentage)

N/A

S.19 Carbon intensity

N/A

S.20 Scope 3 DLT GHG emissions - value chain

N/A

S.21 GHG emissions reduction targets or commitments

N/A

S.22 Generation of waste electrical and electronic equipment (WEEE)

N/A

S.23 Non-recycled WEEE ratio

N/A

S.24 Generation of hazardous waste

N/A

S.25 Generation of waste (all types)

N/A

S.26 Non-recycled waste ratio (all types)

N/A

S.27 Waste intensity (all types)

N/A

S.28 Waste reduction targets or commitments (all types)

N/A

S.29 Impact of the use of equipment on natural resources

N/A

S.30 Natural resources use reduction targets or commitments

N/A

S.31 Water use

N/A

S.32 Non recycled water ratio

N/A

S.33 Other energy sources and methodologies

N/A

S.34 Other GHG sources and methodologies

N/A

S.35 Waste sources and methodologies

N/A

S.36 Natural resources sources and methodologies

N/A